Category: San Francisco

Perhaps you have read Gabe Metcalf’s piece for CityLab titled ‘What’s the Matter With San Francisco? The city’s devastating affordability crisis has an unlikely villain—its famed progressive politics.’ It goes into depth about how policies in San Francisco have lead to the current situation where one bedroom apartments are renting for $82,000 per year. Yes, policies in San Francisco and the surrounding area have lead to very high housing prices. Who is to blame? I have a hard time blaming Progressives (whatever that means these days).

I would argue that in the Bay Area, wealthy single family homeowners have had FAR more sway on maintaining exclusionary zoning and blocking new housing than San Francisco’s progressive politicians. This piece dramatically understates the role of other towns and cities in the region, many of which are located on transit lines, to provide increased density. Yes, it’s not NYC, but BART and Caltrain are better than what most of the country has to work with. Many of the stations on the peninsula are surrounded by one and two story buildings. Even within the City of San Francisco, the majority of residential land is zoned for single family homes. Look at the map my firm worked on with CCA’s Urban Works Agency for a show at SPUR a few months ago, the large light gray areas that dominate the southern and western portion of the city are essentially suburban:

Zoning in San Francisco by Jeffrey Maeshiro and Cesar Lopez of The Urban Works Agency at CCA

Chris Daly (arguably one of the most “Progressive” politicians San Francisco has had in recent years) helped pave the way for the massive number of new units in SOMA by brokering a community impact deal in 2005, and these units are the majority of the housing that has been created in the last 10 years. The Eastern Neighborhoods Plan, which upzoned large areas on the east side of the City, was approved by a Progressive-majority Board of Supervisors. It should also be noted that most of the areas that have been upzoned are less wealthy and more dominated by renters than the areas that are primarily single family.

The line that keeps getting repeated that we should have been building 5,000 units a year is absurd taking into account the realities of development. The math makes sense in the simplest way possible, but we all know that no developer is going to build those units at the bottom of a recession (and the economy is always cyclical), and nobody 25 years ago would have predicted the level of in-migration and income inequality we have right now- even taking the population boom that started in 1980 into account. Far more units than that have been permitted in each boom and in most cases developers have declined to build them (or deferred them until the next cycle). The fact that they haven’t been built has more to do with economics than obstructionism.

Why is housing getting so expensive? There are a number of theories floating around out there. A few popular ones:

Airbnb is tying up thousands of units as rentals

New housing is all being sold purely as investments to Russian and Chinese millionaires/billionaires

Our housing is being bought up as pieds-à-terres by out-of-towners

SPUR commissioned a study of these lines of thinking and the results were pretty underwhelming (I know, I know, a lot of people espousing these three beliefs will argue that SPUR is biased but hold on a second). They found that only about 2.4% of San Francisco’s rental stock was being used for “seasonal, occasional and recreational use.” They found that it was not a significant cause of housing price escalation but came up with the following three policy considerations:

There are pieds-à-terre in both new and old buildings.

New buildings do not create demand for pieds-à-terre.

Recent legislation to limit short-term rentals to units that are someone’s primary residence is going to be important.

Their main conclusion? “San Francisco will need to do a better job collecting this data in the future.” It’s hard to craft policy when the data required is so difficult to collect. This is very important. I would also encourage SPUR and others to look at the effect that platforms have on apartment sharing. Room rentals in shared apartments (historically via newspaper ads, and then Craigslist) make the the biggest pool of affordable housing stock in San Francisco and there is reason to believe Airbnb is having an increasingly large effect on this housing pool. The Chronicle’s research showed that there were about 5,000 rentals available on a given night on Airbnb alone.

That all being said, this is still not an enormous part of the housing market, and with so much new housing being built as rental apartments there isn’t even the opportunity for foreign investors to buy them and leave them vacant.

Okay, so if those aren’t the MAIN reasons why it is so expensive to live here, what on Earth else could it be?

The city has grown by over 100,000 people in just 20 years, and the rate of growth has jumped dramatically since the end of the recession. It’s as if (almost) everyone from Berkeley moved to San Francisco but we didn’t build anywhere to put them.

As indicated in the data at the beginning, housing construction has not kept up. The roughly 10,000 units being kept off the market that were noted in the SPUR study don’t even come close to having the effect of having 45,000 people move here in the last few years, especially when only a few thousand (less than 2,000 net in 2013 for example) units are being built. You can call me a supply-sider if you’d like, but it is pretty obvious that we don’t have enough places for people to live. If there is a beer shortage and it’s really hot outside, people with money are going to be willing to pay A LOT more for the last few cans of Coors.

What types of solutions are being looked at now?

A Housing Bond

There is the housing bond mentioned above. The mayor is proposing a $250 million bond, some people think it should be twice that. With $500 million, the City of San Francisco would have (from the Examiner piece by Cohen and Marti):

$100 million to establish a neighborhood stabilization trust large enough to fund the acquisition of 600 or more units at risk of displacement over the next five years;

$200 million to build up to 1,000 additional affordable units to keep pace with the runaway scale of market-rate and “luxury” developments in the neighborhoods most impacted by gentrification;

$100 million to “land-bank” up to 15 new sites before they become lost opportunities;

$80 million to fill the gap in the HopeSF public housing rebuild;

and $20 million to expand the downpayment assistance program for teachers and other first-time homebuyers.

A Moratorium on Market Rate Housing in the Mission

Wait, I thought there was a shortage of housing… don’t we need more? That’s not what District 9 Supervisor David Campos thinks (read Bernalwood’s coverage here). Despite the fact that very little market rate housing has been built in the Mission, Campos thinks that putting a Moratorium on new development is somehow going to stop gentrification and evictions. All of those people we hear about getting evicted in the Mission (and believe me, it is a problem) are not living in new buildings. They are living in old buildings, which is where new residents end up living because we’re not building anywhere else to put them.

We can’t stop people from moving to San Francisco, as much as some people would like to, and we can’t stop centrally-located neighborhoods with tons of amenities (like the Mission) from being attractive to newcomers. Especially rich newcomers who can live wherever they’d like to.

What we can do, as a city, is not support policy ideas that do nothing to address a critical shortage of housing affordable to people who already live here while increasing the pressure on the existing housing stock (where people already live) to accommodate a population boom.

A few more ideas

Maybe a market rate development at 16th & Mission would be more palatable if the developer paid to get two nearby affordable buildings built?

Mandate information collection from Airbnb and other vacation rental services, and make it easier for hosts to register with the city. The Planning Department should know how many people are using the service, and what impact it has on the housing market. There are a number of pending legislative issues now.

Use existing city funds to move stalled affordable housing projects forward, or direct affordable housing fees from new affordable projects to stalled projects in the same neighborhood. Things are finally moving now on some of these parcels, but why not partner up market-rate developers with the non-profits and find creative ways to get more affordable projects out of the ground as quickly as possible? Mission Local wrote a great piece about stalled affordable projects last year. There are a lot of other projects around the city (not just the Mission) that have affordable housing planned but there isn’t quite enough money to start construction.

San Francisco has risen to huge challenges in the past. The city recovered in a few years from being burned to ground, and managed to house a huge wartime population boom in the 1940s. We need to do anything and everything to solve the housing crisis.

San Francisco rebuilt from the ’06 earthquake faster than we can install a bus turning lane today.

A massive steel I-beam is hammered into the ground like a golf tee or a tent stake, holding up the trolley wires that have run up Market Street since just after the great earthquake in 1906. Before that, horsecars, steam trains and cable cars all took their turn on Market Street’s rails. The beam stands there because the Central Subway is under construction below and there are many moving pieces as workers rearrange everything to make way for the underground concourse.

Beyond the tangle of wires the shiny metal box that is the Apple Store, a reminder that many of the recent developments in city life have nothing to do with the construction of buildings or transport infrastructure but in the way we interact with them.

Let’s assume they can max out the down payment assistance at $200,000 and plug that in as the down payment.

I assumed no other debts. This is pretty unlikely as most people have a car payment, credit card bill or a student a loan (or all three).

I made assumptions about rates (4%), taxes ($7,000/yr) and homeowners insurance ($1200/yr) that may or not be perfect but are close enough.

You can buy a $ 642,773.13 home (in this very simplified calculation).

How many properties are there in this category? Redfin shows 49. Many are either TICs studio units (good luck getting your financing to work out on that if you are trying to get financial assistance from the city) or vacant land. There are admittedly a few actual homes for that price, but it’s slim pickings.

There is a minimum of 1 person for bedroom, so if I couple can only find a 3 bedroom house that meets their criteria they are out of luck.

The buyer must contribute 5% of their own funds to the purchase price ($32,000 for the example above)

The buyer must have three months of reserve funds after purchasing.

There are also other problems- it is very difficult to get a mortgage on a property that is considered a “fixer” in San Francisco (which many of the properties in this price range are) and your offer will not be very competitive on a property with multiple bids. That other couple that isn’t getting down payment assistance will most likely be able to offer more money.

This doesn’t seem like a realistic solution to help solve a housing crisis in its current state, but perhaps part of the program to offer more funding could also change the terms?

I spotted the following headline today on SF Gate: Supervisor wants S.F. to follow state on reforming initiatives and it immediately reminded me that I’d been working on a recap of a number of the planning-related issues that have come up on local ballots recently. Supervisor Wiener’s suggestions make a lot of sense: they both create a clearer process, and help voters make sense of who is funding the campaigns. I think the bar should be raised even higher, but this is a sensible place to start.

A Long History

The ballot in San Francisco is a very special thing. Usually printed on multiple oversized and double-sided sheets of paper, in some election cycles the alphabet has to be started over at AA to fit all of the measures voters are asked to weigh in on. Direct democracy was a result of Progressive-era politics in the late 1800s, lead in part by Governor Hiram Johnson. A special election of the state’s voters in 1911 adopted the initiative, referendum, and recall at both the state and local levels. San Francisco and Vallejo had already adopted the initiative in 1898.

Topics dealt with in these elections range from approval of large bonds to much smaller issues that elicit enough support from a handful of backers (who generally by employ paid signature-gatherers to qualify the measure). If you think an overflowing list of local ballot measures is a recent development, look back almost a century to November of 1907 when there were twenty-two measures before the voters (compared to only twelve this past Election Day) including five separate measures that dealt with land use and infrastructure development.

Issues that would often be better off dealt with legislatively often reach the ballot box first for a variety of reasons, as the pace of change has accelerated dramatically during the current boom. Many of the measures brought for voters’ consideration are in response to the huge amount of construction that has taken place since 2011 and the increase in housing costs that has pushed many people out of the City (and threatened to do so for many others).

November 2013: The Wall on the Waterfront

The battle over the 8 Washington condominium development on the west side of the Embarcadero near the Ferry Building was a high profile campaign funded in large part by Richard and Barbara Stewart, wealthy condo owners who live across the street from where the proposed project was to be built. Unhappy with the approval of the building, they sought to overturn the City’s decision to allow it to go forward.

The opponents of 8 Washington compared it to the demolished Embarcadero Freeway in their campaign materials, calling it the “Wall on the Waterfront.” They also enlisted the support of the San Francisco Chapter of the Sierra Club, and former politicians like Aaron Peskin and Art Agnos also joined the fight.

The campaign consisted of Referendum C, placed on the ballot to overturn the project’s approval with a “no” vote. As has become common in San Francisco, supporters of the development put Proposition B on the same ballot which would have negated C. Both measures failed, meaning the development was halted. This helped set the stage for the 2014 elections.

June 2014: Proposition B

Opponents of 8 Washington saw the chance to channel anti-development sentiment into a larger effort. Rather than trying to overturn waterfront projects on a case by case basis, Proposition B took advantage of their momentum from the previous election combined with the extremely low turnout of a June election to pass a measure that requires voter approval of any project on Port land that exceeds existing height limits, usually forty feet. Specifically crafted in opposition to a planned arena on Piers 30/32, this measure covered development projects spanning the entire eastern side of the city.

Agnos and company succeeded in getting Proposition B passed, but the City of San Francisco was quickly sued by the State Lands Commission. Because Port land is owned by the State of California, the Lands Commission is arguing that the City’s voters have no right to legislate development restrictions on this property. The case is still in the courts now.

November 2014

Following voter approval of Proposition B, the developers of Pier 70 in the Dogpatch put the “Union Iron Works Historic Housing, Waterfront Parks, Jobs and Preservation Initiative” on the ballot as Measure F. This measure sought to approve a 90-foot height limit on the site.

The measure forwarded a plan that had already been in the works for years, and had substantial support in the neighborhood as it promised to create waterfront access for residents in an area that currently sits fenced off an vacant. Many urban planners were hoping for taller buildings in the area, seeing that there are working cranes on other parcels and docked cruise ships in adjacent ship maintenance facility that are well over 200’ tall. Because the measure had to go out to a public vote, the proposal was tailored to fit what its backers were confident would pass.

And pass it did. With 72% of the vote in the November election, Proposition F sailed to an easy victory. It had the backing of several groups that opposed 8 Washington, including the San Francisco Chapter of the Sierra Club. It showed other developers a path forward to developing waterfront parcels on Port land elsewhere in the city if Proposition B holds up in court. It could provide a template for other long-planned projects on the waterfront.

Turf

To voters outside the Bay Area, two ballot measures about an artificial grass soccer field seems like a bizarre misuse of the electoral process. In San Francisco, it’s just another election season. Taking a cue from the “Wall on the Waterfront” battle, this was an attempt by activists to overturn the already-approved plan to install artificial turf and lighting at the western end of Golden Gate Park on what are currently underused grass soccer fields. Unhappy with the outcome of their dealings with the Recreation and Parks Commission, the Planning Commission, the Board of Supervisors, the San Francisco Board of Appeals,the California Coastal Commission, and the California Superior Court (who all were ready to let the project move forward), they decided to take the issue to the voters to override the public process in which they had lost. Thus was born Proposition H, “Requiring Certain Golden Gate Park Athletic Fields to Be Kept as Grass With No Artificial Lighting.”

Proposition I was also on the ballot, this measure was designed to invalidate Proposition H and would set new thresholds for future projects by mandating the City move forward with projects if an environmental impact report states that park use would be doubled with improvements. Proposition I passed with 55% of the vote, with a similar number of people voting no on H.

Transportation

There were multiple transportation-related measures on the November ballot, and the outcome of the election showed a clear preference for improving public transportation. Proposition A was a $500 million bond measure that would pay for infrastructure improvements. Proposition B also sought to increase transportation funding by tying set-asides for Muni to San Francisco’s population growth. Both of these measures passed, Prop A with over 70% and B with over 60%.

Proposition L sought to do the opposite of A & B by reversing San Francisco’s “Transit First” policy through a policy statement. Placed on the ballot by a signature gathering effort, this measure struggled to find support and failed by approximately the same margin that Proposition B won.

Summary

While the battle over 8 Washington set the stage for citizens to challenge the outcome of decisions made through a public process at the ballot box, the message since then has been mixed. June 2014’s Proposition B showed that voters do want to weigh in on development projects, but Proposition F in November showed that some waterfront projects can prove quite popular.

The artificial turf measure sought to overturn a process that has dragged on for years, and the outcome showed voters felt the City was right to approve the project in the first place and Proposition L showed the vast majority of San Franciscans feel that our longstanding city policy of prioritizing transit, cycling and walking is on the right track.

Short of a reform of direct democracy in California, the lack of palatable legislative solutions to contentious issues combined with the availability of big money to back signature gathering efforts and elections will lead to more ballot box decision-making. Time will tell if the will of the people is really reflected in these land use election measures, or if sponsors with the biggest bank accounts will be able to overturn the outcomes of years-long public processes to block projects that they disagree with. While many of San Francisco’s far-left progressives saw the battle over 8 Washington as a way to send a message to large developers of market-rate housing, it is just as easy to imagine affordable housing projects being blocked by unenthusiastic neighbors in a future election.

It will be interesting to see how Supervisor Wiener’s legislative changes are received, there are a lot of people who like the status quo.

Yesterday on Twitter, I posted the question to San Franciscans of what their backup plans were if they had to leave for financial reasons. As rents and housing prices accelerate it’s something I think about almost every day. Even moving to the East Bay is seeming to be less and less of an option as convenient locations near BART are seeing price increases even higher than those in San Francisco proper. I’ve assembled many of the responses (there were a lot!) in my first attempt at using Storify:

Also, I urge you to watch this public television documentary on race relations in San Francisco filmed in 1963 as author James Baldwin is toured around the city as Redevelopment of several city neighborhoods is underway. Here is part of the description from Vimeo:

KQED’s mobile film unit follows author and activist James Baldwin in the spring of 1963, as he’s driven around San Francisco to meet with members of the local African-American community. He is escorted by Youth For Service’s Executive Director Orville Luster and intent on discovering: “The real situation of Negroes in the city, as opposed to the image San Francisco would like to present.” He declares: “There is no moral distance … between the facts of life in San Francisco and the facts of life in Birmingham. Someone’s got to tell it like it is.”

“Let the voters decide” has a certain immediate appeal. It implies that the will of the people will guide public decisions and create a more just and fair city for all. That’s the idea at least. The reality usually ends up looking a lot messier. To say nothing of the huge structural issues direct democracy has caused for the state as a whole (ahem, Proposition 13).

This year, Proposition B purports to make the planning process more fair by letting the public vote on any project that exceeds existing waterfront height limits. Sounds good, right? No more shady backroom deals! Everyone wins, right? Not quite. First, let’s look at the existing height limits. One of the most popular buildings on the waterfront (and in San Francisco as a whole) currently exceeds the forty foot height limit that exists along most of the waterfront and would not be allowed under current planning regulations:

But wait, we can bring the Ferry Building into compliance without going to a vote:

Maybe this seems like a frivolous exercise, but it illustrates the reason why height limits are sometimes exceeded- it makes sense. 40’ is extremely low in an urban area, and most of the waterfront is not so precious that a few taller buildings would make it such a bad place. People often throw out Miami Beach as indicative of the horrible consequences of changing our current 40’ height limits. You know what? Miami Beach’s waterfront is in some ways a much more pleasant place to be than a lot of the Embarcadero, with public access and a surprising lack of huge storage buildings full of parking. Or in other cases, the waterfront is literally surface parking. Perhaps you have heard in campaign literature that the San Francisco Giants want to build high rise condos on land zoned for parks? That’s not quite the case. The Giants have some of the largest surface parking lots in San Francisco that currently take up prime waterfront land which has current height limit of zero. Meaning, without the height limit being exceeded, that “open space” is going to remain surface parking forever instead of turning into housing and a five and half acre park.

Ah, there’s nothing like a little stroll along the waterfront:

Planning at the ballot box doesn’t make sense because the typical voter doesn’t have the time or background to analyze urban design, land use planning, or the tradeoffs involved in various options. A lot of people walk into the voting booth, read the one line description on the ballot, and vote. The current process for exceeding the height limit on a parcel takes years of meetings (public meetings for anyone interested in attending), approval of the Planning Commission, and approval of the Board of Supervisors. Changing a height limit cannot simply be done with an exception to the planning code: it involves rezoning that piece of land at a taller height, and it is not a simple process.

Our current planning process also has a number of public benefits built in. Developers must comply with affordable housing laws (either through a fee or providing on-site units), fees to pay for infrastructure and they are held to public scrutiny at numerous meetings where public comment is collected.

How often to voters read the full text of things they are voting on? Not very often, I can assure you. Developers could hypothetically skip many steps of project approval by spending enough money to get a project approved at the ballot box without having to comply with all of the other rules that have been put in place to ensure a good outcome for the City and the residents of the area. The Port has $1.5 billion in unfunded infrastructure needs, and by their own economic analysis Prop B could result in $8.4 billion in “delayed, reduced or lost revenues to the Port Harbor Fund.” Perhaps the Warriors arena wasn’t the best use of Piers 30-32, but nobody else with enough money has stepped up to keep it from falling into the Bay (except for maybe George Lucas).

In more detail:

Depending on the nature of required ballot measures that would evolve from Proposition B, such measures could enable developers to bypass otherwise mandatory environmental review, professional analysis, public response, commission hearings, and legislative review in advance of the election on the project. The layered review and public processes that exist today evolved after decades of vigorous public discourse, planning, and action, some of which is highlighted in our attached letter, resulting in the Port Lands being the most regulated lands in San Francisco. The current review and public process likely would be altered and occur at different chronological periods in the various stages of project approval. (from the San Francisco Planning Department’s analysis of Measure B)

Back in the 1980s the San Francisco Bay Guardian (and others) waged a campaign to stop the Manhattanization of San Francisco. Ballot measures were passed that severely limited the amount of office space that could be built downtown (to less than the area in one building the size of the Transbay Tower per year). How did that work out? Great, if you like San Francisco turning into a bedroom community for suburban office parks, and you like the high-rise hotels that were built instead of commercial office buildings:

There are a lot of unintended consequences of well-intentioned political efforts. The risks of passing Proposition B are too great, and the benefits are far too small (I personally fail to see any benefits to passing it). I’ve already voted NO and mailed my ballot this morning.

The Mission Bay construction site fire on March 11, 2014 as seen from a BART train in West Oakland (photo by author).

Yesterday’s huge fire on a construction site in San Francisco left people with a lot of questions, some of which were circulating on Twitter as the fire was still burning. The six-story, eighty foot tall uncompleted structure burned out of control for several hours as nearly 150 firefighters fought to contain the flames and keep the fire from spreading to occupied buildings nearby. The apartment building across the street faced heat so intense, 30 windows facing the blaze cracked from the heat.

Many people were surprised that a 180 unit apartment building would be constructed out of wood. This is actually the most common way to build apartments in California, in anything but a high rise. As I’ve pointed out before, housing construction costs are very high and wood construction is usually the most economical way to build condos or apartments up to six stories tall. In some cases, with very large buildings, economies of scale will dictate concrete construction with metal stud walls, but in most cases developers choose to build in wood over a concrete “podium,” which is the platform structure the wood building goes on top of. It usually contains parking, retail, common spaces and sometimes additional housing units. In California, wood construction also has the benefit of performing very well in earthquakes. It is lightweight and its resistance to lateral movement (side to side wind or seismic forces) can be easily increased with plywood shear walls. Unreinforced masonry (brick or concrete block) on the other hand is a disaster in earthquakes– those are the buildings that are required to have warning labels next to the front door (you can’t build those buildings any more under current codes, for obvious reasons).

What is the building code?

The California Building Code (CBC) is based on the International Building Code, which is used all over the United States. It is concerned with prescribing safe methods of designing buildings, and is particularly concerned with safety and accessibility (although there is also a Fire Code that buildings must comply with). There used to be a larger variety of “model codes,” which are codes that the state codes are based upon, but in the late 1990s the various codes were phased out and the IBC was promoted as a national standard. California lagged behind and took longer than the rest of country to decide to adopt it, but the current CBC is based on it with some differences. It is worth pointing out that building construction is also regulated at the local level, for instance San Francisco has its own amendments that are published online. Additionally, there are many other codes that effect construction. The printed versions fill an entire bookshelf or more, covering plumbing, electrical, mechanical, energy use, wildland/urban interface zones, etc. Every building built within a particular jurisdiction has to comply with all of them.

So what are the various types of construction that can be used under the building code?

Every building is designed to fit the requirements of a construction type, of which there are five. The building can be designed out of the materials of a higher type for other reasons, but be evaluated based upon a lower type of construction if desired (i.e. a concrete building evaluated as Type V). There are also subtypes of each of these types:

Types I and II. Types I and II construction are those types of construction in which the building elements are of noncombustible materials, which means steel or concrete.

Type III. Type III construction is that type of construction in which the exterior walls are of noncombustible materials and the interior building elements are of any material permitted by the code. Fire-retardant-treated wood framing is usually used for exterior walls, but traditional brick buildings with wood framing inside are also of this type.

Type IV- (Heavy Timber) Type IV exterior walls are of noncombustible materials and the interior building elements are of solid or laminated wood without concealed spaces. This is typical for old mill buildings, it is based upon the concept that once wood building elements are larger than a certain size they will char and not burn all the way through. Large wood beams and columns of this type are made out of laminated pieces of smaller wood today.

Construction types and compartments can be combined to make up a larger structure. There are area limitations in the code for each construction type and uses that are only allowed in certain types. Fire rated walls must be used to enclose things with higher fire risks, like parking or transformers. The code allows for a ground floor parking garage to be built out of concrete (Type I) with a wood (Type V) building on top of it. This can allow for each portion of the building to be treated as a separate structure. The code allows maximum sizes (areas and heights) for each construction type, and the area get larger as fire resistance goes up (a wood building has to be smaller than a concrete building).

Bonus area is given for certain factors. Including sprinklers and having fire department access on all sides of a building are two things that would allow for additional area of a building under the code. This is done to encourage safer buildings.

Type V construction is actually very safe, once it is finished.

All residential buildings are now required to have sprinklers in new construction in California, even private homes. Large fires are basically unheard of in sprinklered buildings, assuming the system is working. Fire treated walls with drywall on them are very good at stopping the spread of flames. However, when a building is under construction (like we saw yesterday) there is still a big risk of fire until the sprinkler system is installed. There will always be a lag because the building obviously needs to be framed before pipes can be put in.